In order to ensure the smooth operation of our business, our company acquires and retains certain personal information about our clients, including names, addresses, telephone numbers and e-mail addresses ("Personal Information"). We recognize that the proper safekeeping of this Personal Information is an important obligation, and have therefore established the following policies for our handling of all Personal Information.

1. In addition to complying with all laws, regulations, ordinances and guidelines related to the custody of Personal Information, we adopt and implement practices for the appropriate handling of Personal Information that accord with generally accepted public standards, and will strive to improve the suitability and implementation of those practices.

2. We establish clear internal regulations regarding the handling of Personal Information and make these regulations known to all our employees. In addition, we require our trading partners and contractors to handle all Personal Information in an appropriate manner.

3. Upon acquiring any Personal Information, we will specify the purpose for which that information will be used, make a notification or public announcement of that purpose, and only deal with the Personal Information within the scope of that specified purpose.

4. If we engage any third party to deal with all or any part of our Personal Information to the extent required to achieve the purpose of use of that information, before we provide such Personal Information to the third party, we will confirm that the third party has adequate measures for the safekeeping of that information, and will enter into a contract with that third party for the custody of that Personal Information, as well as put in place any other appropriate measures.

5. We will establish the necessary measures and engage in the appropriate supervision to prevent any disclosure or loss of, or tampering with, any Personal Information.

6.If we receive a request from any client in relation to whom we have custody of Personal Information, to disclose, amend, delete or cease using that information, we will respond accordingly in good faith.

(2) Purpose of Use of Personal Information

Our company acquires Personal Information as necessary in the course of undertaking our business, and that Personal Information will be used for one or more of the following purposes.

1. To confirm whether right holders wish to participate in our urban redevelopment business or consulting business, to negotiate with and respond to requests of right holders, parties related to right holders, local residents and administrative authorities in relation to our urban redevelopment business, to enter into contracts with right holders for the sale and purchase of real estate, and to manage those contracts.

2. To provide advisory and consulting activities for our clients, to enter into asset management contract and all other types of contracts with our clients, and to manage those contracts, in relation to asset investment, asset management, real estate investment and the like.

3. To provide all types of services , including responding to inquiries and requests for documentation from customers regarding real estate property including offices, residences, stores, parking lots, conference rooms, exhibition spaces and galleries, to conduct business activities in respect of tenants and other users of real estate, including soliciting tenants, to enter into lease contracts and sale and purchase contracts, to manage those contracts, to conduct day-to-day property management, and to act as an agent for cleaning and housekeeping services.

4. To operate and manage shops and other Retail Facilities, including the provision of all services related to customer membership point programs.

5. To manage the members, staff, exhibitors and participants at institutions such as art galleries, academies (such as Academy Hills) and gardening clubs.

6.To provide guidance and related support for our clients within the facilities that we operate or manage, and to provide operational and management services such as emergency response services and crime prevention services.

7.To respond to inquiries in relation to books, magazines, museum goods and other products, and to take orders for such products, deliver such products, and provide after sales service in relation to such products.

8.To provide services for information communication and the installation of facilities for information communication, to provide consulting services for the foregoing, to manage contracts with contractors for such services, and to provide technological support, maintenance, and notification of difficulties with, such services and facilities.

9.To enter into contracts for the lending of money, and to manage such contracts.

10.In the event that our company is engaged by another business to deal with all or any part of the Personal Information of that business, to undertake that engagement in an appropriate manner.

13.To implement any other activity related to any business of our company.

(3) Management and Custody of Personal Information

Our company will appoint a Personal Information Manager to ensure the proper and strict safekeeping of the Personal Information received from our clients, and will strive to preserve the accuracy of all Personal Information. Furthermore, we will implement the necessary and appropriate level of safety measures to prevent the risk of any Personal Information being disclosed outside of the company and of any improper external access to the Personal Information, based on our Regulations for the Custody of Personal Information and Rules for Dealing with Personal Information.

(4) Provision of Personal Information to Third Parties

Except where required by law, we will not disclose any individual's Personal Information to a third party without the consent of that individual.

(5) Where Disclosure is Requested

In the event that any individual in respect of whom we hold Personal Information wishes us to disclose that information, we will, without delay, after first confirming the identity of the individual making such request, disclose the relevant Personal Information, except where otherwise required by law.

(6) Amendments, Additions and Deletions

In the event that any individual in respect of whom we hold Personal Information wishes that information to be amended, supplemented or deleted, we will, without delay, after first confirming the identity of the individual making such request, effect the relevant change so that the relevant Personal Information is in accordance with fact.

(7) Suspension and Cessation of Use

In the event that any individual in respect of whom we hold Personal Information wishes us to suspend or cease our use of that information or to cease providing that information to a third party, we will, without delay, after first confirming the identity of the individual making such request and ascertaining that there is a reason for the request, effect the relevant suspension or cessation.

2.Fee
Requests for notification of the purpose of use of Personal Information or for the disclosure of Personal Information held will incur a handling fee of five hundred yen (500yen) per request (inclusive of consumption tax and local consumption tax), which may be paid by bank transfer or other methods.